Historic Environment Guidance for Wave and Tidal Energy

Sent: 12 March 2013 11:35
To: 'Antony Firth', Fjordr

Dear Tony,

Thank you for your consultation on the above document. As you are aware ALGAO:UK represents the senior local authority or equivalent archaeologists within the UK, the Maritime Committee provides advice to the Association and others in respect to Maritime matters that relate to ALGAO. The document was circulated to ALGAO members and to the maritime committee and views set out below reflect my comments and the views returned to me by members.

In the first instance we would welcome this as a timely document given the increased activity in this area and the uncertainty over jurisdictions in relation to the marine environment. I set out our principle comments below:-

1.The document would benefit from a Contents List

2.Introduction: Rather than identifying the intended audience within the introduction it would be better to have this under a separate heading, so that you don’t have to look for it. I would also suggest adding into this part a general recommendation for early discussions between all parties to ensure that each understands their respective roles and positions in relation to any single development.

3.Roles and Processes:

  • This would benefit from a clearer statement of the legal responsibilities of all parties, particularly the overlap between local government and the MMO and where the two intersect. This is an area that is still a cause of great uncertainty for Local Authority Curators. This might perhaps be done as an appendix?
  • As well as referring to the Town & Country Planning Act there should be a reference to the National Planning Policy Framework which now guides Local Authority responses.

4.Historic Environment Themes, Assets Types and Contexts

  • I think that a reference to setting needs to be included here. Namely the visual impact of a scheme on the coastal historic environment, particularly where this comprises Conservation Areas or heritage Assets of particular significance e.g. Abbey / Castle ruins etc.

5.Heritage Assets in their Wider Surroundings

  • Having just noted the above, this section then appears at page 23. It seems strange not to have this section next to the Heritage Themes section and they should be grouped together to emphasise the full breadth of the Historic Environment.

General Comments

  • Individual sections might benefit from an opening sentence making it clear which sector might find the particular section useful.
  • There is a descent into detail at the end and it might be better to break the document more clearly into strategic and tactical sections so that it begins by identifying the players, provides the legal and policy framework each is operating in and then examines detail. Again good use might be made of appendices.
  • I would suggest that the sections … ‘Archaeological Data.p33.’, ‘Site Investigation p38…’, ‘Anomalies..p41’, ‘Assessment..p 43’ could be put together in a single Appendix or section with a title such as ‘Requirements of Historic Environment Components to a Project’ .
  • I would exclude ‘Uncertainty and Risk’ from this as a strategic element to be retained with the principle text.

In conclusion we regard this as a useful and worthwhile document, which could be improved by a clearer structure and identification of which sector each section is principally intended for. The feedback I have had on this document is that it is very useful.

Yours sincerely,

Robin Daniels
Chair ALGAO Maritime Committee

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